Proposed Fee Schedule for Reimbursement of Telemedicine

On July 12, 2018, the Centers for Medicare & Medicaid Services (CMS) released a Medicare annual payment rule for calendar year (CY) 2019 that proposes potential changes to Medicare payments for physicians and other health care practitioners.

The rule includes numerous proposals related to telemedicine reimbursement, particularly a new proposal to pay for remote services.  These proposals are described in detail below. Please notice there is a lack of Emergency Telemedicine codes such as emergency evaluation and management and Critical Care.  We are working diligently to push more emergency medicine codes forward. 

ACEP formally submitted comments on the proposed rule on September 10, 2018. 

Physician Fee Schedule Telemedicine Proposals

1. New telehealth service codes under Section 1834m of the Social Security Act

• G0513: Prolonged preventive service(s) (beyond the typical service time of the primary procedure) in the office or other outpatient setting requiring direct patient contact beyond the usual service; first 30 minutes.
• G0514: Prolonged preventive service(s) (beyond the typical service time of the primary procedure) in the office or other outpatient setting requiring direct patient contact beyond the usual service; each additional 30 minutes.

2. New “communication technology-based” service codes not subject to 1834m restrictions

• Virtual check-in – GVCI1 (Brief communication technology based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion)
  • Provided to established patient
  • Not billed separately when originates from related E/M code with same provider or leads to E/M in-person service with same provider
  • De-bundled rate is lower ($14/visit) than existing E/M visit
• Evaluating patient submitted asynchronous video or image – GRAS1 (Remote evaluation of recorded video and/or images submitted by the patient (e.g., store and forward), including interpretation with verbal follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment)
  • • Remote professional evaluation of patient-transmitted information via S&F video or image
    • Could be available to established or new patients
    • Rate is $14/visit
• Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)
  • • Separate payments for GVCI1 and GRAS1 to RHCs and FQHCs outside of the all-inclusive rate and prospective payments system rate
    • New “virtual communications” G code to be billed alone or with other services, and waive F2F requirements
• Separate payment for chronic care remote patient monitoring –
  • • 990X0 (Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment)
    • 990X1 (Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days)
    • 994X9 (Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month)
• Separate payments for interprofessional Internet Consultations --
  • • 994X0 (Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or qualified health care professional, 30 minutes)
    • 994X6 (Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician including a written report to the patient’s treating/requesting physician or other qualified health care professional, 5 or more minutes of medical consultative time)
    • 99446 (Interprofessional telephone/Internet assessment and management service provided by a consultative physician including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 5-10 minutes of medical consultative discussion and review)
    • 99447 (Interprofessional telephone/Internet assessment and management service provided by a consultative physician including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 11-20 minutes of medical consultative discussion and review)
    • 99448 (Interprofessional telephone/Internet assessment and management service provided by a consultative physician including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 21-30 minutes of medical consultative discussion and review)
    • 99449 (Interprofessional telephone/Internet assessment and management service provided by a consultative physician including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 31 minutes or more of medical consultative discussion and review)

3. Guidance for acute stroke telehealth

• New modifier used by the distant and originating site to identify acute stroke telehealth services
• Add mobile stroke unit to the list of originating sites
• Excludes renal dialysis facilities and patient homes as originating sites

 4. Guidance for remote kidney dialysis assessment coverage

• Add renal dialysis facilities and patient’s home to the list of originating sites for purposes of home dialysis monthly ESRD related assessment enhancements;
• No geographic restrictions for originating sites that are hospital-based or critical access hospital-based renal dialysis centers, renal dialysis facilities, or the patient’s home,
• No originating site fee for the patient’s home

5. Creation of a new payment bundle for “Care for Management and Counseling Treatment for Substance Use Disorders

• Bundled episode-based payment that would be beneficial to improve access, quality and efficiency for SUD treatment
• Development of coding and payment for a bundled episode of care for treatment for SUDs that could include overall treatment management, any necessary counseling, and components of a MAT program such as treatment planning, medication management, and observation of drug dosing
• Specifically, CMS is seeking public comments related to what assumptions they might make about the typical number of counseling sessions as well as the duration of the service period, which types of practitioners could furnish these services, what components of MAT could be included in the bundled episode of care, and how to define and value this bundle and what conditions of payment should be attached.

Alexander Chiu, MD
Alternate Councillor
ACEP Telemedicine Section